UNITED STATES OF AMERICA DEPARTMENT OFTRANSPORTATION FEDERAL AVIATIONADMINISTRATION WASHINGTON, DC

Regulatory Docket

# No.~)

# j-**~)t)** ,

IN THE MATTER OF THE PETITION FOREXEMPTIONOF: Mike Cleary 

### FORAN EXEMPTION SEEKING RELIEF FROMTHE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 

### 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(l) & 

### (a)(2), AND 91.417(a) & 

### (b) CONCERNINGCOMMERCIAL OPERATION OF YUNEEC QSOO TYPHOON QUADCOPTERUNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MQDERlSIZATION AND 

### REFOBM ACI 

### OF 2012 (PJJBIJC LAW 112-95)

Submitted on September, 18 2015 Mike Cleary 6628 Carmel Trail Wilmington, NC 28404 336-529-8033TABLE OFCONTENTS Page GLOSSARY OF ABBREVIATIONS

........................................................................................ 3 SUMMARY

................................................................................................................................ 4 INTRODUCTION AND INTERESTS OF PETITIONER

........................................................4 BACKGROUND

............................................................................................................................5 BASIS FORPETITION

...............................................................................................................5 NAME AND ADDRESS OF PETITIONER

...............................................................................8 THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH MIKE CLEARY SEEKS EXEMPTION

........................................................................................................................ 8 THEEXTENT OF RELIEF MIKE CLEARY AND THEREASON MIKE CLEARY SEEKS THE RELIEF

............... 8-11 THE REASONS WHY GRANTING MIKE CLEARY'SREQUEST WOULD BE IN THE PUBLIC INTEREST

............................................................................................................... 15 THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY

.................................................................................................................... 19 SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER.

.......................33 ANY ADDITIONAL INFORMATION, VIEWS, ORARGUMENTS AVAILABLE TO SUPPORT Mike CLEARY'S REQUEST

................ 3434 CONCLUSION

.............................................................................................................................. 34 APPENDICES

........................................................................................36

2

### AGL AOI ATC ATO AV CFR COA FAA FAR GCS GPS LOL NAS NOTAM PIC Section 333 

## so SOP UA UAS VFR VLOS VMC VTOL GJ,OSSARY 

## OF ABBBE\TJATIQNS 

### Above GroundLevel Area oflnterest Air Traffic Control Air Traffic Organization Aerial Vehicle Code ofFederal Regulations Certificate ofAuthorization Federal Aviation Administration Federal Aviation Regulation Ground Control Station Global Positioning System Loss ofLink National Airspace System Notice to Airman Pilot In Command FAA Modernization and Reform Act of2012 (FMRA) Section 333 Safety Observer Standard OperatingProcedures Unmanned Aircraft Unmanned Aircraft System Visual Flight Rules Visual Line ofSite Visual Meteorological Conditions Vertical Takeoffand Landing

3

### SUMMARY Mike Cleary seeks exemption from the requirements of 14 C.F.R 

### §§ 61.113(a) & (b), 91.7(a), 91.121, 91.15l(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) 

### & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act of2012 (FMRA). This exemption will permit Mike Cleary to operate an Unmanned Aircraft System (UAS) for thecommercial purpose ofconducting aerial video and photography ofconstruction sites, real estate, and landscape over certain areas of the United States. 

### INTRODUCTION AND INTEBESJS OF THE PETITIQNEB Mike Cleary provides clients with expertise and knowledge inadvanced technologies and solutions to increase efficiency, productivity and effectiveness. He holds

anAirline Transport Rating, and has twenty three years ofcommercial airline operational experience. The objective Mike Cleary's aerial video andphotography operations is to provide high quality imaging for a variety ofcommercial, public, andresidential uses, specifically targeting: Real estate and private property aerialphotography Aerial acquisitions used for inspections ofpublic and private structures. Increase public knowledge ofUAS and promote safe UASoperations.



### 4BACKGROIJNQ Unmanned Aircraft Systems: Yuneec 

### QSOO Typhoonquadcopter Mike Cleary seeks an exemptionto operate DJI systems for compensation orhire within the NAS. The Yuneec 

### QSOO Typhoon quadcopter is a vertical takeoffand landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The Yuneec 

### QSOO Typhoon quadcopter has a maximum gross weight ofapproximately 2 pounds 11 ounces, while having a length of 14 inches width of 14 inches, height of8.5 inches, and a maximum speed ofapproximately 29 knots. The Yuneec 

### QSOO Typhoon quadcopter is equipped with four mainrotors; driven by Lithium Polymer battery powered electric motors. The Yuneec 

### QSOO Typhoon quadcopter UAS that will be operated by Mike Cleary will be registered 

### in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.RPart 47, AircraftRegistration, and marked 

### in accordance with 14 C.F

### .R. Part 45, Identification andRegistrationMarking. JlA§IS FOR PETITION Petitioner, Mike Cleary, pursuant to the provisions ofthe Federal Aviation Regulations (14 C.F

### .R. 

### § 11.61) and the FAA Modernization and Reform Act of2012 (FMRA), Section 333, Special Rules for Certain UnmannedAircraftSystems, hereby petitions the Administrator to commercially operate the Yuneec 

### QSOO Typhoonquadcopter UAS 

### in the National Airspace System (NAS), and for an exemption from the requirements of14C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) 

### & (b).



### 5In consideration ofthe speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, Mike Cleary's operation ofYuneec Q500 Typhoon quadcopter UAS meets the conditions ofFMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F

### .R. Part 21, Subpart H. Accordingly, Mike Cleary requests relieffrom Sections91.405(a), 91.407(a)(l), 91.409(a)(1) & (a)(2), and 91.417(a) & 

### (b), as these sections setforth requirements for maintenance that only apply to aircraft with an airworthiness certificate. Mike Cleary submits that the requested reliefis proper since anequivalent level of safety will be ensured. Mike Cleary will use experiencedpersonnelor technicians to perform maintenance, alterations, orpreventive maintenance onthe UASs using the methods, techniques, and practices prescribed inthe operating documents (i.e., Monthly Maintenance Log, and Yuneec QSOO Typhoon quadcopter InstructionManual). Furthermore, Mike Cleary will document and maintain all maintenance records for the Yuneec QSOO TyphoonquadcopterUAS. Relieffrom certain requirements ofSection 61.113(a) and 

### (b), entitled Privatepilot privileges and limitations: Pilot in command, is requested by Mike Cleary tothe extent necessary to allow a Pilot in Command (PIC) holding a private pilot orhigherlevel certificate, as well as an airman medical certificate, and who 

### has demonstrated, by meeting minimum flight- hour and currency requirements, that the PIC is able to safely operatethe Yuneec QSOO Typhoon quadcopter UAS in a manner consistent withthis exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

6Mike Cleary seeks relieffrom Section 91.7(a), entitled Civilaircraft airworthiness, because the Yuneec QSOO Typhoon quadcopter UAS does not requirean airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Carl H. Schneider submits that he will ensure that the Yuneec QSOO Typhoon quadcopter UAS is in an airworthy condition, priorto every flight, by determining that the UAS isin compliance with the operating documents (i.e., Monthly Maintenance Log, and Yuneec QSOO Typhoon quadcopter Instruction Manual), and thatthe aircraft is 

### in a conditionfor safe flight. Mike Cleary also seeks an exemption from the requirements ofSection 91.121, entitledAltimeter Settings, as the Yuneec QSOO Typhoon quadcopter UA will not have a typical barometric altimeter onboard. However, altitude information ofthe Yuneec Q500 Typhoon quadcopter UA will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring ofthe flight path. This altitude information, combined with Mike Cleary's operation ofthe Yuneec Q500 Typhoon quadcopter UAS within visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section91.121. Additionally, Mike Cleary seeks an exemption from the requirements ofSection 91.151(b), entitled Fuel requirements for flight in VFR conditions. Mike Cleary submits that safety will not be affected by operation ofthe Yuneec Q500 Typhoon quadcopter UA during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration of

7approximately 14 minutes 

### to the first point ofintended landing and, assumingnormal cruising speed, to fly afterthat for at least 5 minutes. In accordance with 14 C.F.R 

### § 11.81, Mike Cleary provides the following information in support ofits petition for exemption: 

### A. Name And Address OfThe Petitioner. The name and address ofthe Petitioner and point ofcontact is: Mike Cleary 6628 Carmel Trail Wilmington, NC 28404 336-529-8033 

### B. The Specific Sections Of 14 C.F.R. From Which Mike Cleary Seeks Exemption. 1. Mike Cleary Seeks Exemption FromThe Requirements OfSection 61.113(a) And (b). Section 61.113, entitled Private pilot privileges and limitations: Pilot incommand, subsections (a) and (b) prescribethe following, inrelevantpart: (a) No person who holds a private pilot certificate may act as a pilot in command (PIC) ofan aircraft that is carrying passengers orproperty for compensationor hire; nor may thatperson, for compensation orhire, act as PIC ofanaircraft. (b) A private pilot may, for compensation orhire, act as PIC ofan aircraftin connection with any business or employment 

### if- (1) The flight is only incidental to that business or employment;and (2) The aircraft does not carry passengers or property for compensation orhire.



### 2. Mike Cleary Seeks ExemptionFromTheRequirements OfSection 91.7(a). Section 91.7, entitled Civil aircraft airworthiness, subsection (a), statesthe following:



### 8(a) No person may operate a civil aircraft unless it is in an airworthycondition. 3. Mike Cleary Seeks Exemption From TheRequirements OfSection 91.121. Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part: (a) Each person operating an aircraft shall maintain the cruising altitude or flight level ofthat aircraft, as the case may be, by reference to an altimeter that isset, when operating-- (1) Below 18,000 feet MSL, 

### to-- (i) The current reported altimeter setting ofa station along the route and within 100 nautical miles ofthe aircraft; (ii) Ifthere is no station within the area prescribed inparagraph (a)(l)(i) of this section, the currentreported altimeter setting ofanappropriate available station; or (iii) Inthe case ofan aircraft not equipped with a radio, the elevation ofthe departure airport or an appropriate altimeter setting available before departure. 4. Mike Cleary Seeks Exemption From The Requirements OfSection 91.151(b). Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), states thefollowing: (b) Noperson may begin aflight in a rotorcraft under VFR conditionsunless (considering windand forecast weather conditions) there is enough fuel to fly to thefirstpoint of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes. 5. Mike Cleary Seeks Exemption From The Requirement OfSection 91.405(a). Section 91.405, entitledMaintenance required, subsection (a), states thefollowing: Each owner or operator ofanaircraft9(a) Shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided inparagraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter[.] 

### 6. Mike Cleary Seeks Exemption From The Requirements OfSection 91.407(a)(l) Section 91.407, entitled 

### Operation after maintenance, preventivemaintenance, rebuilding, or alteration, subsection (a)(l), statesthefollowing: (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alterationunless-- 

### (1) Ithas been approved for return to service by a person authorized under§ 43.7 ofthis chapter[.] 

### 7. Mike Cleary Seeks Exemption From The Requirements OfSections 91.409(a)(l) And 91.409(a)(2). Section 91.409, entitled

### Inspections, subsection (a), states thefollowing: (a) Except as provided in paragraph (c) ofthis section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had-- (1) An annual inspection in accordance with part 43 ofthis chapter andhas been approved for return to service by a person authorized by § 43.7 ofthis chapter; or (2) An inspection for the issuance ofan airworthiness certificate in accordance with part 21 ofthis chapter. 

### 8. Mike Cleary Seeks Exemption from the Requirements of Sections 91.417(a) And 91.417(b). Section 91.417, entitled 

### Maintenance records, subsections (a) and (b), statethe following: (a) Except for work performed in accordance with§§ 91.411 and 91.413, each registered owner or operator shall keep the following records forthe periods specified inparagraph (b) ofthis section: 

### (1) Records ofthe maintenance, preventive maintenance, and alteration and records ofthe 100-hour, annual, progressive, and other required orapproved inspections, as appropriate, for each aircraft (including the airframe) and

10each engine, propeller, rotor, and appliance ofan aircraft. The records must include-- (i) A description (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date ofcompletion ofthe work performed; and (iii) The signature, and certificate number ofthe personapproving the aircraft for return to service. (2) Records containing the following information: (i) The total time in service ofthe airframe, each engine, eachpropeller,and eachrotor. 

### (ii) The current status oflife-limitedparts ofeach airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul ofall items installed onthe aircraft which are required to be overhauled on a specifiedtime basis. (iv) The currentinspection status ofthe aircraft, includingthe time since the last inspection required by the inspectionprogram under whichthe aircraft and its appliances are maintained. (v) The current status ofapplicable airworthiness directives (AD) and safety directives including, for each, the method ofcompliance, the AD or safety directive number and revision date. Ifthe AD or safetydirective involves recurring action, the time and date when the next action is required. (vi) Copies ofthe forms prescribed by§ 43.9(d) ofthis chapter foreach major alterationtothe airframe andcurrently installedengines, rotors, propellers, and appliances. (b) The owner or operator shall retainthe following records for the periods prescribed: (1) The records specified in paragraph (a)(1) ofthis section shall be retained until the work isrepeated or superseded by otherworkor for 1 year after the work is performed. (2) The records specified in paragraph (a)(2) ofthis section shall be retained and transferred withthe aircraft at the time the aircraft is sold.

11(3) A list ofdefects furnished to a registered owner or operator under§ 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service. C. The Extent OfReliefMike Cleary Seeks And The Reason Mike Cleary Seeks The Relief. 1. Extent OfReliefMike Cleary Seeks And The Reason Mike Cleary Seeks ReliefFrom Section 61.113(a) And (b). Relieffrom Section 61.113(a) and (b) entitled Privatepilotprivilegesand limitations: Pilot in command, is requested to the extent necessary to allow a PIC holdinga private pilot or higher level certificate, as well as a current and valid airman medical certificate, and who has met certain flight-hour and currency requirements, to conductthe proposed UAS flight operations for compensation orhire. This reliefis requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation orhire, act as PIC ofan aircraftin connection with any business oremployment if: (1) The flight is only incidental tothat business or employment; and (2) The aircraft does not carry passengers orproperty for compensation orhire. As setforth more fully below, Mike Cleary submits that an equivalentlevel of safety willbe maintained because no PIC will be allowedto operate the Yuneec Q500 Typhoon quadcopter UAS unless that PIC has met certain flight-hour and currency requirements, demonstrating that the PIC is able 

### to safely operate the YuneecQ500 Typhoon quadcopterUAS in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriatedistances from people, vessels, vehicles and structures.



### 12Further, Mike Cleary submits that all flights of the Yuneec QSOO Typhoon quadcopter UAS, conducted by the PIC pursuant to the grant ofthis Petition: (1) willbe incidental to Mike Cleary's business; and (2) will not carry passengers or property for compensation orhire. 

### 2. Extent OfReliefMike Cleary Seeks And The Reason Mike Cleary Seeks ReliefFrom Section 91.7(a). Relieffrom Section 91.7(a) entitled Civil aircraft airworthiness, is requested tothe extent required to allow Mike Cleary to determine that the Yuneec Q500Typhoon quad copterUAS is in airworthy conditionpriorto every flight byensuring thatthe UAS is in compliance with the operating documents (i.e., Monthly Maintenance Log, andYuneec QSOO Typhoon quadcopter InstructionManual). Mike Cleary seeks the requested reliefbecause the Yuneec QSOO Typhoon quadcopter UAS does notrequire an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Mike Cleary will ensure thatthe Yuneec QSOO Typhoon quadcopter UAS is in airworthy condition based upon its compliance withthe operating documents (i.e., Monthly Maintenance Log, and Yuneec QSOO Typhoon quadcopter Instruction Manual) prior to every flight, and further, determine thatthe aircraft is in condition for safe flight, as stated inthe conditions and limitationsbelow. 

### 3. Extent OfReliefMike Cleary Seeks And The Reason Mike Cleary Seeks ReliefFrom Section 91.121. Relieffrom Section 91.121, entitled Altimeter settings, may be required toallow flight operations ofthe Yuneec QSOO Typhoon quadcopter UAS, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data linkto downlink altitude information from the UA to the PIC atthe ground control station (GCS). Since the FAArequires that any altitude information concerning UAS operations

13be reported to air traffic control (ATC) in feet above ground level (AGL), Mike Cleary seeks the requested reliefbecause the Yuneec 

### QSOO Typhoon quadcopterUA altimeter may be set onthe ground to zero feet AGL, rather than the localbarometric pressure or field altitude, before eachflight. Considering the limited altitude ofthe proposed operations, relieffrom 14 CFR 91.121 is sought to the extent necessary to comply withthe applicable conditions and limitations statedbelow. As more fully setforth herein, an equivalent level ofsafety will be maintained since the Yuneec Q500 Typhoon quadcopter UA is equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each flight, and provides the PIC with altitude information ofthe UA onthe heads-up display oftheGCS. 

### 4. Extent OfReliefMike Cleary Seeks And The Reason Mike Cleary Seeks ReliefFrom Section 91.151(b). Relieffrom Section 91.151(b) entitled Fuel requirements for flight inVFR conditions, is requested to the extent required to allow flights ofthe batterypowered Yuneec 

### QSOO Typhoon quadcopter UA during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 14 minutes to the first point ofintended landing and, assuming normal cruising speed, to fly afterthat for at least 5 minutes. Mike Cleary seeks the requested reliefbecause withoutan exemption from Section 91.151(b), the flight time duration ofthe battery powered Yuneec Q500 Typhoon quadcopter UA will severely constrain the practicality ofany aerial video or stillphoto flight operations that Mike Cleary proposes to conduct pursuant to thisPetition. Significantly, as set forth below, the technical specifications ofthe Yuneec 

### QSOO Typhoon quadcopter UAS, the Yuneec Q500 Typhoon quadcopter operating documents, 

### 14Mike Cleary's proposed operating limitations, ensure that Mike Cleary will safely operate the battery powered Yuneec 

### QSOO Typhoon quadcopter UAduring daylight hoursin visual meteorological conditions (VMC), undervisual flight rules (VFR), with enough battery power to fly for a total duration of 14 minutes to the first point of intended landing and, assuming normal cruising speed, to fly afterthat for at least 5 minutes. 

### 5. Extent OfReliefMike Cleary Seeks And The Reason Mike Cleary Seeks ReliefFrom Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & 

### (a)(2), And 91.417(a) & 

### (b). Since Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) 

### & (a)(2), and 91.417(a) 

### & (b) only apply to aircraft with an airworthiness certificate, Mike Cleary requests relieffrom these Sections because the Yuneec 

### QSOO Typhoon quadcopter UAS does notrequire airworthiness certificates. As setforth more fully below, the Yuneec 

### QSOO Typhoon quadcopter UAS meets the conditions ofFMRA Section 333 for operation without an airworthiness certificate. Accordingly, Mike Cleary will use trained technicians to perform maintenance, alterations, orpreventive maintenance on the UASs using the methods, techniques, and practices prescribed inthe UAS operating documents (i.e., Monthly Maintenance Log, and Yuneec 

### QSOO Typhoon quadcopter). Furthermore, Mike Cleary will document and maintain all maintenance records for the Yuneec 

### QSOO Typhoon quadcopter UAS. 

### D. The Reasons Why GrantingMike Cleary's Request Would Be InThe Public Interest; That Is, How ItWould Benefit The Public As 

### A Whole. Granting the present Petition will further the public interest by allowing Mike Cleary to safely, efficiently, and economically perform aerial videoand photography ofconstruction sites, real estate, and landscape over certain areasof the United States.



### 15Additionally, use ofthe Yuneec Q500 Typhoon quadcopter UAS will decrease congestion ofthe NAS, reduce pollution, andprovide significant benefits to the economy. Notably,the benefits ofMike Cleary's proposed operation ofthe Yuneec Q500 Typhoon quadcopter UAS will be realized without implicating any privacy issues. 

### 1. The Public Will Benefit From Decreased Congestion OfTheNAS. The Ytmeec Q500 Typhoon quadcopter UA is battery powered and serves as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount ofmanned aircraft needed to perform aerial acquisitions, an exemption allowing the use ofa Yuneec Q500 Typhoon quadcopterUAS would reduce the amount ofmanned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety oflife and property inthe air and onthe ground. Furthermore, by reducing the number ofmanned aircraft operating intheNAS, congestion around airports caused by arriving and departing aircraft will bereduced. The Yuneec Q500 Typhoon quadcopter UA does notrequire an airport to takeoffor land. Likewise, a reduction ofmanned aircraft conducting aerial video andphotography missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases offlightoperations. 

### 2. The Public Will Benefit From The Safety And Efficiency OfThe Yuneec Q500 Typhoon quadcopter UAS. Conducting aerial acquisitions with the Yuneec Q500 Typhoon quadcopter UAS, instead ofmanned aircraft, will greatly benefitthe public by drastically reducing the levels ofair and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and electric motors, theYuneec Q500 Typhoon quadcopter UAS produces no airpollution, and is the most viable environmentally 

### 16conscious alternative to the cabin class, six cylinder internalcombustion engine aircraft thatare typically utilized for aerial video and photography, while burning approximately 20-30 gallons per hour ofleaded aviation fuel. The Yuneec 

### QSOO Typhoon quadcopter UA,while reducing the carbon footprint ofaerial acquisitions, also eliminates noise pollution, asthe UAs are propelledby battery poweredelectric motors, rather than an internal combustionengine. By using the Yuneec 

### QSOO Typhoon quadcopter UAS to performaerial acquisitions, the substantial risk to life and property inthe air and onthe ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack offlight crewmembers located onboard the aircraft, the Yuneec 

### QSOO Typhoon quadcopter UA (weighing approximately 2 pounds 11 ounces, at its maximum gross weight with a length of 14 inches, widths of 14 inches, and withno fuel onboard), has less physical potential for collateral damage to life and property onthe ground, and inthe air, compared to the manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan ofapproximately 42 feet, a length of34 feet, and a fuel capacity of 180gallons).



### 173. Performing Aerial Video and Photography Operations With The Yuneec Q500 Typhoon quadcopter UAS Will Benefit TheEconomy. In addition to being safe and efficient, the Yuneec QSOO Typhoon quadcopterUAS is also an economical alternative to using manned aircraft to conduct similaraerial operations. As such, operation ofthe Yuneec Q500 Typhoon quadcopter UAS willallow United States based companies, like Mike Cleary's, to remain competitiveand contribute to growthofthe U.S. economy. Specifically, withthe rising cost ofaviation fuel and the Environmental Protection Agency ("EPA") regulatory actions phasing outleaded aviation fuels, U.S. owned and operated companies must adoptnew and alternative technology in order to remain competitive. Operating the battery powered YuneecQ500 Typhoon quadcopter UASs is one suchtechnology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the highoperational cost ofa traditional mannedaircraft. By operating the Yuneec Q500 Typhoon quadcopter UAS, companies such Mike Cleary's, canremain competitive and profitable, and therefore, provide greater job stability to employees and contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial performance ofU.S. companies, throughcommercial

use ofthe Yuneec Q500 Typhoon quadcopter UAS, provides a stable workforce that increases consumer spending; improves local, state, and federal taxrevenues; and allows companies to invest 

### in research and development in order to remain competitive both in the United States andabroad.

184. There Are No Privacy Issues. Similar to the manned aerial acquisition flight operations that have been conductedfor decade Mike Cleary's proposed operation ofthe Yuneec QSOO Typhoonquadcopter UAS will not implicate any privacy issues. Specifically, the Yuneec QSOO Typhoon quadcopter UAS will be operated only in compliance with operating documents (i.e., Monthly Maintenance Log, and Yuneec QSOO Typhoon quadcopter) whichrequires property owner involvement as well as local law enforcement notification, andin accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.P.R.§ 91.119.



### 19E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, OrHow The Exemption Would Provide A Level OfSafety At Least Equal To That Provided By The Rule From Which Mike Cleary SeeksExemption. 1. Reasons Why The Yuneec Q500 Typhoon quadcopter UA Meets The Conditions OfThe FAA Modernization and Reform Act of2012 (FMRA) Section 333. In consideration ofthe size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, Mike Cleary's operation oftheYuneec 

### QSOO Typhoon quadcopter UAS meets the conditions ofFMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F

### .R. Part 21, SubpartH. Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to users ofthe NAS or the public, or otherwise pose a threatto national security. Specifically, FMRA Section 333 statesthe following, inpart: (a) In General.--Notwithstanding any other requirement of this subtitle, andnot later than 180 days after the date of enactment of thisAct, the Secretary of Transportation shall determine 

## if certain unmannedaircraft systems may operate safely in the national airspace system before completion of theplan andrulemaking required by section 332 of thisAct or the guidance required by section 334 of thisAct. 

### (b)) Assessment of UnmannedAircraftSystems.--ln making the determination under subsection (a), the Secretary shall determine, ata minimum-- 

### (1)) which types of unmannedaircraft systems, 

### if any, as a result of their size, weight, speed, operational capability, proximity to airports and populatedareas, andoperation within visual line of sight do notcreate a hazard to users of the national airspace system or thepublic orpose a threat to national security; and (2) ) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 oftitle 49, UnitedStates Code, is required for the operation of unmannedaircraft systems identified underparagraph 

### (1). (c) Requirements for Safe Operation.--lfthe Secretary determines underthis section that certain unmannedaircraftsystems may operate safely in the

20national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airspace system. In seeking this exemption, Mike Cleary submits thatthe Yuneec QSOO Typhoon quadcopter UAS can operate safely inthe NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics ofthe Yuneec Q500 Typhoon quadcopter UAS; (b) the pilot certification requirement; and (c) the specific operating limitations.



### a. The Specifications OfThe Yuneec Q500 Typhoon quadcopterUAS Demonstrate Its Safe Characteristics. The Yuneec Q500 Typhoon quadcopter UAS does not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability. 

### i. Technical Specifications OfThe Yuneec Q500 Typhoonquadcopter UAS. The technical specifications ofthe Yuneec Q500 Typhoon quadcopter UAS isset forth by the Yuneec Q500 Typhoon quadcopter Specifications and Data Sheet,attached hereto as ExhibitA. 

### ii. 

### The Yuneec Q500 Typhoon quadcopter UAS AutonomousFlight And Navigation Modes Enable The UASs To RemainWithin A Defined OperationalArea. The Yuneec Q500 Typhoon quadcopter UAS may be operated inboth manual and fully autonomous flight modes. A complete description ofthe flight and navigational modes ofthe Yuneec QSOO Typhoon quadcopter UAS is provided at pages 25-35 of the Yuneec Q500 Typhoon quadcopter and pages 12-16 User Manual, attached hereto as Exhibit B. 

### iii. 

### The Yuneec Q500 Typhoon quadcopter UAS is DesignedFor Automatic Return To Home Point OrHoverIn The Event Of Loss OfThe Control Link OrNavigation. When the Control Link is lost, the Yuneec Q500 Typhoon quadcopter UAwill 

### 21remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the Yuneec QSOO Typhoon quadcopter Professional UA does not reacquire control link data from the GCS, the UAs will assume that the Control Link is lost and the UAs will return to thehome position (i.e., failsafe mode) via GPS, and will descend to the takeoffposition and shutdown. A complete description ofthe Failsafe Functions ofthe Yuneec QSOO Typhoon quadcopter UAS are set forth atpages 27 through 29 ofthe Yuneec QSOO Typhoon quadcopter User Manual, attached hereto as ExhibitB. 

### iv. The Yuneec Q500 Typhoon quadcopter GCS And ItsOperation. A complete description ofthe operation and specifications ofthe Yuneec QSOO Typhoonquadcopter GCS and flight control software is provided at pages 32 through 43 ofthe Yuneec QSOO Typhoon quadcopter User Manual. Yuneec QSOOTyphoon quadcopter User Manual is attached hereto as ExhibitsB. 

### b. Flight Operations OfYuneec Q500 Typhoon quadcopter UAS is Limited To The Line OfSight OfA Certificated Pilot inCommand With A Safety Observer. Mike Cleary will only utilize certificated pilots who possess a current and valid airman medical certificate to act as a pilot in command (PIC) of the Yuneec QSOO Typhoon quadcopter UAS. Additionally, a safety observer will assist all pilots during flight time.



### c. Flights OfYuneec Q500 Typhoon quadcopter UAS Will BeConducted Pursuant To Specific OperatingLimitations. In seeking this exemption, Mike Cleary proposes to commercially operate Yuneec QSOO Typhoon quadcopter UAS for the special purpose ofconducting aerial video and photography over certain areas ofUnited States, pursuant to the following specific operating limitations: 

### 221. Operations authorized by this grant ofexemption will be limited to the following aircraft described in the operating documents, rotorcraftUASs weighing less than 55 pounds maximum gross weight: Yuneec Q500 Typhoon quadcopterUnmanned Aircraft Systems. Proposed operations ofany other aircraft will require a new petition or a petition to amend thisgrant. 2. UAS operations under this exemption will be limited to conducting operations for the purpose ofaerial video andphotography. 3. The UAs may not be flown at an indicated airspeed exceeding 20knots. 4. The UA must be operated at an altitude ofno more than 400 feet above ground level (AGL), as indicated by the procedures specified inthe operating documents unless a special request is made and approved by ATC. All altitudes reported to ATC must be 

### in feet AGL. 5. The UA mustbe operated within visual line ofsight (VLOS) ofthe PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified onthe PIC's FAA-issued airman medical certificate. 6. The use offirst person view (FPV) by the PIC or safety observer (SO) is not permitted. 7. All operations must utilize a safety observer (SO). The SO may be usedto satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The SO and PIC mustbe able to communicate verbally at all times. Electronic messaging ortexting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration ofthe flight. The PIC must ensure that the SOcan performthe functions prescribed inthe operating documents. 8. The SO must not perform any other duties beyond assisting the PIC withseeing and avoiding other air traffic and other ground based obstacles/obstructions and is not permitted to operate the camera or other instruments. 9. The operating documents and the grant ofexemption must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations contained inthe grant ofexemption and the procedures outlined inthe operating documents,the conditions and limitations contained in the grant of exemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined inits operating documents. The operator may update orrevise its operating documents. It is the operator's responsibility to track suchrevisions and present updated andrevised documents to the Administrator upon request. The operator must also present updated and revised documents ifit petitions for extension or amendment to the grant ofexemption. Ifthe operator determines thatany 

### 23

### update or revision would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendment to its grantof exemption. The FAA's UAS Integration Office (AFS-80) may be contacted ifquestions arise regarding updates or revisions to the operating documents. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. Ifthe inspection reveals a condition that affects the safe operation ofthe U.A.S, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must beproperly documented in the aircraftrecords. 10. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement ofa flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the aircraftrecords. 11. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered inthe relevant sections ofthe operating documents. 12. The operator must follow the UAS manufacturer's aircraft/component, maintenance, overhaul, replacement, inspection, and life limitrequirements. 13. The operator must carry out its maintenance, inspections, and recordkeeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status ofreplacement/overhaul component parts must be noted in the aircraft records, including total time in service, description ofwork accomplished, and the signature ofthe authorized person returning the UAS to service. 14. Each UAS operated under this exemption must comply with all manufacturer Safety Bulletins. 15. The authorized person must make an entry in the aircraft record 

### of the corrective action taken against discrepancies discovered between inspections. 16. The PIC must possess at least a private pilot certificate and at least acurrent third- class medical certificate. 17. The operator may not permit any PIC to operate unless the PIC meetsthe operator's qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated underthe exemption, including evasive and emergency maneuvers andmaintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in amanner consistent with 14 C.F.R. 

### § 

### 61.51(b). Flights for the purposes oftraining the operator's PICsare permitted under the terms ofthe exemption. However, training operations may only be conducted during dedicated training sessions. Duringtraining, proficiency, and experience-building flights, all persons not essential for flight 24operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. 

### § 91.119. 18. UAS operations may notbe conducted during night, as defmed in 14 C.F.R. 

### § 18.1. All operations must be conducted under visual meteorological conditions (VMC). Ifflight atnight is required, a special request will be made atthe FAA office closestto proposed area ofoperations. Flights under special visual flight rules (SVFR) are not authorized. 19. The UA may not operate within 5 nautical miles ofan airport reference point as denoted on a current FAA-published aeronautical chart unless a letter of agreement withthat airport's management is obtained, and the operationis conducted in accordance with a NOT AM as required by the operator's COA. The letter ofagreement withthe airport management mustbe made available to the Administratoruponrequest. 20. The UA may notbe operated less than 500 feet below or less than 2,000feet horizontally from a cloud or when visibility is less than 3 statute miles fromthe PIC. 21. Ifthe UA loses communications or loses its GPS signal, itmust return to a predetermined location withinthe planned operating area and land orbe recovered in accordance with the operating documents. 22. The PIC must abortthe flight in the event ofunpredicted obstacles or emergencies in accordance withthe operating documents. 23. The PIC is prohibited from beginning a flight unless (considering windand forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 25% batterypower remaining. 24. The operator must obtain anAir Traffic Organization (ATO) issued Certificate ofWaiver or Authorization (COA) priorto conducting any operations underthe grant ofexemption. This COA will also require the operatorto request a Notice to Airman (NOT AM) notmore than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted inaccordance with airspace requirements inthe ATO issued COA including class of airspace, altitude level and potential transponderrequirements. 25. All aircraft operated in accordance with the exemptionmustbe identified by serial number, registered in accordance with 14 C.F.R. part47, andhave identification (N- Number) markings in accordance with 14 C.F.R. part45, Subpart C. Markings mustbe as large aspracticable. 26. Before conducting operations, the radio frequency spectrum used for operation and control ofthe UA must comply with the Federal Communications



### 25Commission (FCC) or other appropriate government oversight agency requirements. 27. The documents required fewer than 14 C.P.R. 91.9 and 91.203 mustbe available to the PIC atthe Ground Control Station ofthe UAS any time the UAS is operating. These documents must be made available tothe Administrator or any law enforcement official uponrequest. 28. The UA mustremain clear and yieldthe right ofway to all mannedaviation operations and activities at all times. 29. The UAS may not be operatedby the PIC from any moving device orvehicle. 30. Flight operations mustbe conducted at least 500 feet from all nonparticipating persons (persons other

### than the PIC, SO, operatortrainees or essentialpersons), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protectnonparticipating persons from the UA and/or debris inthe event ofan accident.The operator must ensure that nonparticipating persons remain under such protection. Ifa situation arises where nonparticipating persons leave such protection and are within 500 feet ofthe UA, flight operations mustcease immediately and/or; b. The aircraft is operated near vessels, vehicles or structures wherethe owner/controller ofsuchvessels, vehicles or structures hasgranted permission and the PIC has made a safety assessment ofthe riskof operating closer to those objects and determined that it does notpresent an undue hazard, and;

c. Operations nearer to the PIC, SO, operator trainees or essentialpersons do not present an undue hazard to those persons per 

### §91.119(a). 31. All operations shall be conducted overprivate or controlled-accessproperty withpermission from the land owner/controller or authorized representative. Permissionfrom land owner/controller or authorizedrepresentative willbe obtained for each flight to be conducted. 32. Any incident, accident, or flight operationthat transgresses the lateral or vertical boundaries ofthe operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents mustbe reported to the National Transportation SafetyBoard (NTSB) per instructions contained onthe NTSB Web site: www.ntsb.gov. 

### 2. Reasons Why An Exemption From The Requirements Of Section61.113(a) And (b) Would Not Adversely AtTect Safety.



### 26Mike Cleary submits that the equivalent level ofsafety established bySection 61.113(a) and (b) will be maintained because no PIC will be allowed to operate theYuneec Q500 Typhoon quadcopter UAS unless that PIC has demonstrated, by meetingminimum flight-hour and currency requirements, that the PIC is able to safely operate theYuneec Q500 Typhoon quadcopter UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles andstructures. Considering Mike Cleary's proposed area ofoperations, and theoperating limitations set forth-above; the parallel nature ofprivate pilot aeronauticalknowledge requirements to those ofcommercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate the Yuneec Q500 Typhoonquadcopter UAS, Mike Cleary submits that the additional manned airmanship experience ofa commercially certificatedpilot would not correlate to the airmanship skills necessary for Mike Cleary's specific proposed flight operations. The FAAhas previously granted relieffrom Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. ExernptionNos. 11062,11063,11064,11065,11066,11067,11080,11109,11110,11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). Mike Cleary will not allow any PIC to operate the Yuneec Q500 Typhoon quadcopter UAS unless that PIC has demonstrated, by meeting minimumflight-hour requirements or the Yuneec QSOO Typhoon quadcopter UAS training and currency requirements, that the PIC is able to safely operate the Yuneec QSOO Typhoon quadcopter UAS in amanner consistent with this exemption, including evasive and emergency

maneuvers and maintaining appropriate distances from people, vessels, vehicles and 

### 27structures. Specifically, the PIC must have accumulated and logged, in a mannerconsistent with 14 C.F.R. 

### § 61.51(b), 25 hours oftotal time as a UAS rotorcraft pilot (with a minimum of5 hours ofthose hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings inthe preceding 90 days (forcurrency purposes). As in Exemption Nos. 11062, 11138, and 11153, prior documentedflight experience that was obtained in compliance withapplicable regulations will ensure an equivalent level ofsafety during Mike Cleary's proposed operations.The Administrator has held that prior documented flight experience that was obtainedin compliance with applicable regulations would ensure'safe operations, stating as follows: In ExemptionNo. 11062, the FAA required that prior to conducting operations for the purpose ofmotion picture filming (or similar operations), the PIC musthave accumulated and logged, in a manner consistent with 14 CFR 61.51

### (b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi-rotor UAS. Prior to operations under Exemption No. 11062,the PIC must also have accumulated and logged a minimum of5 hours as a UAS pilot operating the same make and model ofUAS to be used for operations under the exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included inthe 10 hours ofmulti-rotor time and the 10 hours may be includedin the total25 hours ofUAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings inthe preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight·hourrequirements inExemption No. 11062 are appropriate to practice and build proficiency inthe skills necessary to safely conductthe petitioner's proposed operations. TheFAA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency, and experience-building flights can also be conducted under the grant of exemption to accomplish the required flight time. During training, proficiency, and

28experience-building flights the PIC is requiredto operate the UA withappropriate distances in accordance with 14 C.F.R 91.119. ExemptionNo. 11138 at page15. Accordingly, Mike Cleary will ensure safe operations by not allowing any PIC to operate the Yuneec QSOO Typhoon quadcopter UAS unless that PIC has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able tosafely operate the Yuneec Q500 Typhoon quadcopter UAS in a manner consistent withthe exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles andstructures. 

### 3. Reasons Why An Exemption From The Requirements Of Section91.7(a) Would Not Adversely Affect Safety. The equivalentlevel ofsafety establishedby Section 91.7(a) will be maintained because prior to every flight, Mike Cleary will ensure that the Yuneec Q500 Typhoon quadcopter UAS is in an airworthy conditionbased uponthe 

### VAS's compliance with its operating documents and as stated inthe conditions and limitations herein. Additionally, the FAA has previously granted relieffrom Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein( e.g. ExemptionNos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136,11138,11150,11153,11156,11157,11158,11159,11160, 11161). 

### 4. Reasons Why An Exemption From The Requirements OfSection 91.121 Would Not Adversely Affect Safety. The equivalent level ofsafety established by Section 91.121 willbe maintained because the altitude information ofthe Yuneec Q500 Typhoon quadcopter UA willbe provided to the PIC via GPS equipment and a radio communications telemetry datalink, which downlinks from the UA to the GCS for active monitoring ofthe flight path and altitude. 

### 29This altitude information, combined withMike Cleary's operation oftheYuneec QSOO Typhoon quadcopter UA within visual line ofsight, at orbelow 400 feet AGL,will ensure

a level ofsafety equivalentto Section 91.121. The altitude information willbe generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically established by the UASs at groundlevel. The FAAhas previously granted relieffrom Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption }Jos. 11062,11063,11064,11065,11066,11067,11080,11109,11112,11136,11138, 11150,11153,11156,11157,11158,**11159,11160,11161~** 5. Reasons Why An Exemption From The Requirements OfSection 91.151(b) Would Not Adversely Affect Safety. A grant ofthis exemption would ensure an equivalent level ofsafety establishedby 14 C.F.R. Section 91.151(b) as a result of(1) the technical specifications oftheYuneec Q500 Typhoon quadcopterUAS; (2) the limitations onthe proposed flight operations; and (3) the location ofthe proposed flight operations. Accordingly, Mike Cleary will ensure that it will safely operate the battery powered Yuneec Q500 Typhoonquadcopter UA during daylight hours in VFR conditions, with enough battery power to fly for atotal duration of 14 minutes to the first point ofintended landing and, assuming normalcruising speed, to fly afterthatfor at least 5 minutes. Here, as inExemption }Jo. 11109, the technical specifications ofthe Yuneec Q500 Typhoon quadcopter UAS; the limitations onthe proposed flight operations; and the location ofthe proposed operations, will ensure an equivalent level ofsafety establishedby 14C.F.R. Section 91.15l(b). Furthermore, safety will be ensured as the Yuneec QSOO Typhoon quadcopter UAS provide audible and visual warnings to the PIC at the GCS when the UAs experiences lowbattery voltage, the first warning occurring at 

### 30approximately 33% remaining battery power, and again at approximately 10%remaining battery power. At the critically low battery level, the Yuneec Q500 Typhoonquadcopter UAS will descend and landautomatically. Significantly, previous exemptions granted bythe FAAconcerning Section 91.151 establish that safety is not adversely affected when the technical characteristicsand operating limitations ofthe UAS are considered. Reliefhas been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151,including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously grantedrelief from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. ExemptionNos. 8811, 10808, 10673, 11042, 11062, 11063, 11064,11065,11066,11067,11080,11109,11110,11136,11138,11150,11153,11156, 11157, 11158, 11159, 11160, 11161). 6. Reasons Why An Exemption From The Requirements OfSections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety. In seeking this exemption, Mike Cleary submits thatthe equivalent levelofsafety withregard to the regulatory maintenance and alterationrequirements establishedby Sections 91.405(a), 91.407(a)(l), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because Mike Cleary will use trained technicians to perform maintenance,alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed inthe operating documents (i.e., Monthly Maintenance Log, and Yuneec Q500 Typhoon quadcopter Instruction Manual). Furthermore, Mike Cleary willdocument and maintain all maintenance records for the Yuneec QSOO Typhoon quadcopterUAS.



### 31Since the Yuneec Q500 Typhoon quadcopter UAS will be inspected asprescribed bythe operating documents, Mike Cleary will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(l), and 91.409(a)(2). A copy ofthe Yuneec Q500 Typhoon quadcopter User Manual is attached hereto as Exhibit B; a copy ofthe Yuneec Q500 Typhoon quadcopter UAS Maintenance LOG is attached hereto as Exhibit C. Likewise, the exemption sought will not adversely affect safety because Mike Cleary will use trained technicians to perform maintenance, alterations orpreventive maintenance onthe UAS using the methods, techniques, and practices prescribed by the operatingdocuments. Furthermore, the exemption sought would maintain an equivalent level of safety established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance ofthe Yuneec Q500 Typhoon quadcopter UAS will be performed by trained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log. Significantly, previous exemptions granted by the FAA concerningSections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) establish that safetyis not adversely affected whenthe technical characteristics and operating limitations of the UAS are considered. In consideration ofMike Cleary's proposed operating limitations, the operating documents, and the technical aspects ofthe Yuneec Q500 Typhoonquadcopter UAS, Mike Cleary submits that safety will not be adversely affected bygranting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(l) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAAhas previously grantedreliefspecific to UAS incircumstances similar, in all material respects, to those presentedherein (e.g. ExemptionNos. 11062,

3211063, 11064, 11065, 11066, 11067, 11080, 11109, ll110, 11112, 11l36, 1l138, 11150, 11153,11156,11157,11158,11159,11160, 11161). 7. The FAA May Prescribe Any Other Conditions For Safe Operation. In accordance with Section 333 ofthe PAA Modernization and Reform Act of2012 (PMRA) and 14 C.P.R.§ 21.16 entitled Special Conditions, Mike Cleary requeststhat the FAA prescribe special conditions for the intended operation ofthe Yuneec Q500 Typhoon quadcopter UAS, which contain such safety standards that the Administrator finds necessary to establish a level ofsafety equivalent to that established by 14C.F.R. Part21, Subpart H, and 14 C.P.R §§ 61.113(a) 

### & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(1) & (a)(2), and 91.417(a) & 

### (b). Such special conditions will permit safe operation ofthe UAs for the limited purpose ofconducting aerial video and photography over certain areas ofthe United States for compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users ofthe NAS orthe public, or otherwise pose a threat to national security; andfurther, provides the authority for such UAS to operate withoutairworthiness certification in accordance with any requirements that must be established for the safe operation ofthe UAS 

### intheNAS. Likewise, the Administrator may prescribe special conditions pursuant to 14 C.P.R. § 21.16, for operation ofthe Yuneec Q500 Typhoon quadcopter UAS, since the airworthiness regulations of 14 C.P.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel orunusual design features ofthe aircraft. Section 21.16, entitled Special Conditions, states thefollowing: Ifthe PAA fmds that the airworthiness regulations ofthis subchapter do notcontain adequate or appropriate safety standards for anaircraft, aircraft engine, orpropeller



### 33because ofa novel orunusual design feature ofthe aircraft, aircraft engineor propeller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 ofthis chapter and contain such safety standards for the aircraft, aircraft engine orpropeller asthe FAA finds necessary to establish a level ofsafety equivalent to that establishedin theregulations. See 14 C.P.R.§ 21.16. Therefore, in accordance withFMRA Section333 and 14 C.P.R.§ 21.16, the FAA may prescribe special conditions for Mike Cleary's intended operation ofthe Yuneec Q500 Typhoon quadcopter UAS, which contain such safety standards that the Administrator finds necessary to establish a level ofsafety equivalentto that established by 14 C.P.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) 

### & (b), 91.7(a),91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(l) & (a)(2), and 91.417(a) & (b). 

### F. A Summary That Can Be Published In The Federal Register, stating: TheRules From Which Mike Cleary SeeksExemption: Mike Cleary seeks exemption/rom the requirements of 14 C.F.RSections 61.113(a)&(b), 91. 7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and91.417(a) &(b). 

### A BriefDescription OfThe Nature OfThe Exemption Mike Cleary Seeks: This exemption willpermitMike Cleary to commercially operatean Unmanned Aircraft System (UAS)for thepurpose of conducting aerial video and photography over certain areas of the UnitedStates. 

### G. Any Additional Information, Views, OrArguments Available To Support Mike Cleary's Request. This Petition is made pursuant to the FAA Modernization and Reform Act of2012 (FMRA) Section 333, which directs the Secretary ofTransportation to determine ifcertain UAS may operate safely inthe NAS. As such, Mike Cleary's request forexemption may be granted pursuant to the authority ofFMRA Section 333 and 14 C.F.R. Part 11,as set forthabove.

34FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazardto users ofthe NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate withoutairworthiness certification. As discussed in detail above, Mike Cleary will operate the Yuneec 

### QSOO Typhoon quadcopter UAS safely in the NAS, without creating a hazard to users ofthe NAS, orthe public, or otherwise pose a threat to national security. 

### CQNCLl!SION As setforth herein, Mike Cleary seeks an exemption pursuantto 14C.F.R. 

### § 11.61 and Section 333 ofthe FAA Modernization and Reform Act of2012(FMRA), which will permit safe operation ofthe Yuneec 

### QSOO Typhoon quadcopterUAS commercially, without an airworthiness certificate, for the limited purpose ofconducting aerial video andphotography over certain areas ofthe United States. By grantingthis Petition, the FAA Administrator will be fulfilling the Congressional mandate oftheFAA Modernization and Reform Act of2012, while also advancing the interests ofthe public, by allowing Mike Cleary to safely, efficiently, and economically operate theYuneec 

### QSOO Typhoon quadcopter UAS commercially within theN AS. 

### WHEREFORE, in accordance withthe Federal Aviation Regulations and theFAA Modernization and Reform Act of2012, Section 3 33, Mike Clearyrespectfully requests thatthe Administrator grantthis Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) 

### & (a)(2), and 91.417(a) 

### & (b), andpermit Mike Cleary to operatethe Yuneec 

### QSOO Typhoon quadcopter UAS commercially for the purpose ofconducting aerial video



### 35andphotography over certain areas ofthe UnitedStates. Dated: May 20,2015

Appendices: Respectfully submitted, Mike Cleary

Mike Cleary 6628 Carmel Trail Wilmington, NC 28404

A- Yuneec Q500 Typhoon quadcopter Specifications DataSheet 

### B- Monthly Maintenance Log

36APPENDIX-A 

### YUNEEC Q500 TYPHOON QUADCOPTERTECHNICAL SPECIFICATIONS Mike Cleary only utilizes safe and reliable UASs. Yuneec is an industry leader in small UAS production. Yuneec UASs are loaded with ground breaking software enabling the userto set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher 

### than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, Yuneec software provides real-time altitude and location informationto the PIC viathelinked monitor. 1.1 Yuneec Q500 Typhoon quadcopter 1.1.1 Aircraft 1.1.1.1 Supported Battery- Yuneec 5400 mah LiPo Battery 1.1.1.2 Weight (Battery 

### & Propellers Included)- 60.0 oz (1700 g) 1.1.1.3 Hover Accuracy (Ready to Fly)- Vertical: .8m; Horizontal:2.5m Max Yaw Angular Velocity

- 200°/s 1.1.1.4 Max Tilt Angel- 350 1.1.1.5 Max Ascent Speed- 

### 6mls 1.1.1.6 Max Descent Speed-2m/s 1.1.1.7 Max Flight Speed-15m/s (NOT RECOMMENDED) 1.1.2 Gimbal 1.1.2.1 Working Current- Static: 750mA; Dynamic: 900mA 1.1.2.2 Control Accuracy

- ±0.030 1.1.2.3 Controllable Range -Pitch: -900

- 

## oo 1.1.2.4 Maximum Angular Speed- Pitch: 900/s 1.1.3 Camera 1.1.3.1 Operating Temperature Range

- 32°F

- 1 040F (0°C

- 400C) 1.1.3.2 Sensor Size -1/2.3" 1.1.3.3 Effective Pixels- 14M 1.1.3.4 Resolution- 4384x3288 4.1.3.5 HD Video Recording- 1080p 60,50,48 fps 4.1.3.6 Recording Field ofView -1100/85° 1.1.4 Transmitter 1.1.4.1 Operating Frequency- 5.728GHz-5.85GHz 1.1.4.2 Communication Distance (unobstructed)- FCC Compliance:600m 1.1.4.3 Receiver Sensitivity (1 %PER)

- -93dBm 1.1.4.4 Transmitter Power -FCC Compliance: 1OOm W 1.1.4.5 Working Voltage -120mA@3.7V

37MONTHLY MAINTENANCE LOG month:.

____ ,(year:

___ _

Oate(lssue( Date(lssue( OiscOv&red Addressed lssue(Descriptlon(&(Maintenance(Conducted Maintenance(Performed(By:((( Print(&(Sign Software(Updates Airframe( Engines Propellers Camera(Gimbal landing(Gear Vibration(Dampening

Other:



### 39**~=~:~~~(**

### ~:~::' lssue(Descriptlon(&(Maintenance(Conducted**!'int(&(~gr>_ 'ftwaoe(Upua~>**  'Airframe( •Engines Propellers

IIDr• 

## ... Other:



### 40